According to this article in The Times, Lloyd’s TSB expects to pay a £180 million fine, or about $350 million, to the Department of Treasury’s Office of Foreign Assets Control (“OFAC”) for transactions with companies and individuals in embargoed countries. No detail is given on the specific payments involved, but it’s reasonable to speculate that it involves a number of payments to Cuba and Iran given the size of the anticipated penalty. The anticipated £180 million fine outpaces the $80 million payment made by ABN Amro in 2005 and the $100 million fine paid by UBS to the Federal Reserve in 2004 for transactions with sanctioned countries.

The Times reporter, however, seems to have more or less made up her description of the applicable OFAC regulations rather than speaking with anyone who was actually familiar with them:

America banned banks from carrying out transactions in the US in dollars for people or businesses from the countries on its blacklist in the hope that this would starve terrorists of funding.

Er, no. Transactions in foreign currencies are covered as are transactions carried out by branches of U.S. companies outside the United States. Perhaps I shouldn’t be so critical since I’d probably have as much trouble with the rules of cricket as the Times reporter had with OFAC’s much more complex rules.

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